activities are in fact legal for under 18s, for example gambling privately with friends or, in relation to the 16-year-olds, participating in lotteries, buying lottery scratch cards or using low stakes gaming machines. Tim Miller, Executive Director of the Commission, clarified that “most of the gambling covered by this report takes place in ways which the law permits.”

Online gambling

Despite the overall reduction in gambling by 11-16-year-olds, the Commission found that the proportion who had taken part in online gambling in the past week increased from 1% to 3%. To some extent this may reflect the gradually increasing revenues for online gambling generally, but it is most likely that the finding reflects the changed method of delivering the survey. For the first time this year the Commission’s survey was delivered entirely online. By contrast, Cardiff found a figure of 1.2% had gambled online. It should also be noted that the actual figures involved in the Commission’s survey are an increase from 40 individuals to 81, so extrapolating to the overall population of 3m is unlikely to be accurate. Of those children who gamble online, the majority do so using a parent or guardian’s account with their permission. There is little that an online gambling operator would be able to do to prevent this occurring, but with the knowledge that this is happening operators might want to consider providing information to parents on the risks of underage gambling and/or highlighting the ways that they can set limits on their accounts.

Gambling with adults

A particularly interesting finding by the Commission is the large increase in the last year in the proportion of young people gambling in the presence of an older family member or guardian, as compared to in an unsupervised context. In 2019, 67% gambled with a parent compared to 52% in 2018. This may be partially explained by the introduction of more stringent age verification requirements online, leading young people to request access to a parent’s account, but only a small proportion of underage gambling takes place online. On the assumption that parents and

guardians are the best placed to make decisions as to when their children are mature enough to engage in risky activities and that their presence is likely to reduce problem gambling behaviour such as chasing losses, supervised gambling by children should be much less of a concern than unsupervised gambling. The increase in children gambling alongside a parent or guardian is therefore a positive development. If the Commission were to expand the scope of the research in the future, it would be very useful to map those

34 NOVEMBER 2019

experiencing problem gambling against those gambling in a supervised or unsupervised context, to establish if this is in fact the case.

Impact of advertising

Growing concern around exposure of children to gambling adverts is borne out by the Commission’s findings. Although there were some changes to the questions asked, over the last four years children seeing gambling advertised on TV seems to have increased, with 56% now saying that they see a gambling advert at least once a week. It will be interesting to see what impact the “whistle to whistle” ban on sports betting adverts has on this figure in next year’s survey results, though the most common advert seen was for the National Lottery. One finding which should be concerning to

operators is that 11% of 11-16-year-olds had received direct marketing about gambling, by email, text message or direct messaging through social media. This would indicate that at least 350,000 direct messages were sent to people who should not have received them, although the figures do not account for 16-year-olds who received communications about the National Lottery, which would not be an issue. It is not an offence to send marketing material to a child unless this is done intentionally and there is no requirement at the moment to verify the age of individuals before sending marketing material to them. However, should this figure increase the Commission may look to introduce new LCCP provisions. Consistent with the findings last year, 7% of those surveyed had been prompted to spend money on gambling after seeing an advert.

Problem gambling

The rate of young people suffering from or at risk from problem gambling is arguably the most important statistic in the reports, with the Commission finding that 1.7%, representing approximately 55,000 11-16 year olds in the whole population, are experiencing problem gambling behaviour. A further 2.7% were found to be at risk. As a comparison, the Commission’s latest research into problem gambling rates in adults found that 0.5% of adults are problem gamblers and 1.1% are at moderate risk.

The Cardiff University researchers found

that 16% of young people who had gambled in the last year felt bad as a result. They also found that children from ethnic minorities were both more likely to participate in gambling and more likely to experience harm. One important factor to bear in mind when comparing the figures is that a different set of questions was used in the Commission’s survey to the one it uses when assessing problem gambling rates in adults and that Cardiff only asked about “feeling bad”. The figures indicate that young people who gamble are more likely to experience problems than adults, but this cannot be concluded with certainty given that a different measure was used.

What could be very useful to gambling

operators is a breakdown of the types of harm experienced, as compared to the types of gambling engaged in by the relevant children. If a particular gambling product is more risky than others in terms of those children taking part experiencing a particular type of harm, then efforts to prevent access and educate children and their parents could be focused in the most effective places. Unfortunately, the published data does not give this analysis. Only 50% of 11-16-year-olds had been spoken

to about the potential problems that gambling can lead to by a family member, teacher, charity or similar. This is consistent with previous years. Increasing this figure may be the key to reducing the number of young people who get into difficulties with their gambling.

Takeaways for gambling operators

Although the Commission’s survey reveals a reduction in the number of children gambling, it clearly remains a problem, particularly for the minority who experience harm as a result or are at risk of harm. One area which gambling operators would be wise to focus on is seeking to reduce direct marketing to underage individuals, perhaps beginning by analysing what proportion of their marketing database has not been age verified. Providing information to customers on the risks of underage gambling by children using their account would also be a positive step.

Melanie is a gambling regulatory lawyer with 13 years’ experience in the sector. Melanie advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control. She has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and novel product ideas.

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